Ezel / Tax Rulings / CT
CT Ruling 89-214 Sales and Use Taxes 1989-11-15

Which water- and sewer-plant engineering and building-design services were taxable under Connecticut Ruling 89-214?

Short answer: General engineering was not taxable, but design work for a permanent building housing process facilities was taxable. Subcontracted building design could be bought for resale, while easily disassembled mobile control-building design was not taxable. DRS says AN 94(3) obsoleted the ruling.

Apply this to your situation

This page answers the general question as of 1989. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1989
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official 1989 Connecticut Department of Revenue Services Ruling reflecting the engineering and building-design rules then in effect. DRS expressly says Announcement (AN) 94(3) obsoleted it. Its distinctions among general engineering, permanent process-building design, subcontracted services, and easily disassembled mobile control buildings should not be assumed current. Connecticut imposes sales and use tax solely at the state level: there are no local or municipal sales taxes. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about your specific situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Note -- obsolete historical guidance. DRS states that Announcement (AN) 94(3) obsoleted this ruling.

Plain-English summary

DRS said the requester's general engineering services were not taxable. The portion of water- and sewer-plant design related to a permanent building needed to house process facilities was taxable.

If the requester subcontracted those building-design services, it could buy them on a resale certificate and charge tax to its customer. Design of small mobile control buildings that could be easily disassembled was not taxable as building engineering.

What this means for you

The historical ruling separated permanent building design from general process engineering and easily disassembled mobile control buildings. AN 94(3) later obsoleted the guidance.

Common questions

Were general engineering services taxable? No under the ruling.

Was permanent plant-building design taxable? Yes.

Could subcontracted building design be purchased for resale? Yes, with tax then charged to the customer.

Was mobile control-building design taxable? Not when the small building could be easily disassembled.

Citations and references

  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-214, Engineering

Ruling 89-214

Engineering

This Ruling has been obsoleted by   AN 94(3)

From the information contained in your letter, your engineering services are not subject to tax. However, the portion of your design of water and sewer plants which relates to a permanent building required to house the process facilities is subject to tax. If you subcontract the building design services, you may purchase these services on a resale certificate and charge tax to your customer. In this regard, the Department does not consider the design of small, mobile control buildings that can be easily disassembled to be taxable as building engineering services.

LEGAL DIVISION

November 15, 1989

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